Modern Slavery and Human Trafficking Statement 2025

Introduction

At Reward Gateway | Edenred, people are at the heart of everything we do. We are committed to promoting dignity, fairness, and respect, and to preventing modern slavery and human trafficking across our operations and supply chains. We recognise that modern slavery is a serious global issue, and we take our responsibility to identify, prevent, and address risks of forced labour, child labour, human trafficking, and other forms of exploitation seriously.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 (Cth). It applies to Reward Gateway’s AUKUS operations—Australia, the United Kingdom, and the United States—and also covers our entities in Bulgaria and India.

While modern slavery legislation currently applies only in the UK and Australia, we have chosen to extend the principles and commitments set out in this statement across all Reward Gateway | Edenred entities. We believe this reflects our values and our responsibility to promote fair, ethical, and respectful practices consistently, regardless of jurisdiction.

It has been approved by the Board of Directors of Reward Gateway | Edenred and outlines the actions we take to help ensure modern slavery does not occur within our business or supply chains.

As part of the Edenred Group, and together with our community of more than 6,000 clients and 10 million members, we strive to use our influence for good. We work collaboratively with our suppliers and partner organisations to identify, prevent, and address modern slavery risks, focusing on transparency, continuous improvement, and meaningful remediation. Where concerns arise, we seek to support positive change and will not knowingly tolerate unresolved or unmanaged modern slavery practices.

Reward Gateway | Edenred today

10m+ employees supported through our products

6k+ clients who trust us

7+ offices in four countries

1,000+ RGER people globally

Our Business

Reward Gateway | Edenred is a culture‑ and client‑driven organisation. Since 2006, we have worked alongside some of the world’s most forward‑thinking HR, reward, and people leaders, supporting them with tools and solutions that help their people feel valued, connected, and engaged.

Today, we support more than 10 million employees worldwide, helping them connect, recognise, and support one another—contributing to workplaces where people and organisations can thrive. Our employee engagement platform brings together recognition, reward, wellbeing, surveys, benefits, and discounts, enabling organisations to attract, retain, and grow talent in line with their values.

As part of the Edenred Group, we share a global ambition to bring more joie de vivre (Joy of Living) into the world of work—those small, positive, everyday moments that make people feel appreciated, supported, and able to do their best work.

Below is a list of our four global trading entities, including their registered company numbers, addresses, and employee headcount as at 31 December 2025, the end of the reporting financial year.

Operations

Founded in London in 2006, Reward Gateway | Edenred has grown into a global organisation employing more than 1,000 people across four countries. We operate from offices in London and Chester (UK), Sydney and Melbourne (Australia), Plovdiv and Sofia (Bulgaria), and Boston and Rochester (USA).

Our Group Leadership Team has responsibility for the oversight and direction of our operations, helping to ensure consistency, accountability, and alignment with our values across all locations.

Our Supply Chains

While we deliver our core services, including engineering, largely in‑house—where we have strong oversight and control—we also work with a broad network of suppliers to support our business. This is particularly the case in the delivery of our benefits and rewards offering, where partnerships play an important role in creating value for our clients and their employees.

Our supply chain includes two main categories of suppliers:

• Retail partners, who work with us to provide benefits and reward products to our clients and their employees; and

• Direct suppliers and business partners, who provide a range of products and services that support our global operations, including partners whose solutions we integrate and deliver as part of our offering to clients.

We recognise that our supply chain is an extension of our business and our values, and we are committed to working responsibly with our suppliers and partners to promote fair treatment, transparency, and ethical practices.

Our Relationships with Third Parties

We expect the same commitment to ethical and responsible behaviour from our suppliers, agents, and business partners as we do from ourselves. The principles and values set out in the Edenred Charter of Ethics apply to all third parties with whom we work.

These expectations are formalised through the Edenred Supplier Charter, which defines clear standards for ethical business practices, safe working conditions, fair treatment of workers, respect for human rights, and environmental responsibility. The Supplier Charter applies to all suppliers, agents, and contractors working with Edenred and Reward Gateway | Edenred and forms a core part of Edenred’s Sustainable Procurement Policy.

By asking our suppliers to acknowledge and adhere to the Supplier Charter, we aim to promote transparency, accountability, and alignment with our social responsibility, human rights, and ethical standards across our supply chain.

Our Policies

Our approach to preventing modern slavery is grounded in our values and reinforced by clear policies and shared responsibilities across the business. As part of the Edenred Group, we are guided by the Global Edenred Human Rights Principles, which reflect our commitment to respecting the fundamental dignity and rights of people throughout our value chain.

This commitment is supported by the Edenred Charter of Ethics, Human Rights Policy, and Supplier Charter, which together set out clear expectations for ethical conduct, human rights protection, and responsible business practices across our value chain. These frameworks establish clear expectations relating to freedom of movement, transparent employment contracts, supplier compliance, due diligence and risk management, workplace safety and dignity, and reporting and enforcement through Edenred’s whistleblowing mechanism.

Employees receive education on the risks of modern slavery and are supported to recognise potential indicators or concerns. At Reward Gateway | Edenred, this is complemented by our location-specific Employee Handbooks, which are shared with every employee on joining the business and serve as a key reference point for our mission, culture, behaviours, policies, and ways of working.

The Employee Handbooks reinforce our zero‑tolerance approach to bullying and harassment through our Anti‑Harassment and Bullying Policy, our commitment to ethical and transparent business conduct through our Anti‑Bribery and Corruption Policy, and provide clear guidance on how employees can speak up and raise concerns through our Whistleblowing Policy. Together, these policies help create a safe, respectful, and accountable environment where people are encouraged to act in line with our values.

Our Stance on Modern Slavery and Human Trafficking

Given the nature of our business, we consider the overall risk of modern slavery within our operations and supply chain to be lower than in many other sectors. However, we are clear that low risk does not mean no risk. We are committed to remaining alert, reflective, and proactive in strengthening our policies, processes, and partnerships to help ensure that modern slavery and human trafficking do not occur within our business or across our supply chain.

We take a zero‑tolerance approach to modern slavery and human trafficking. We expect the same standards from the organisations we work with, and we require our suppliers and contractors to, at a minimum, comply with the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 (Cth). Beyond legal compliance, we aim to work collaboratively with our partners to promote ethical practices, transparency, and continuous improvement.

Due Diligence

We take a risk‑based approach to due diligence across our operations and supply chain. This includes embedding ethical and human rights considerations into supplier selection processes, verifying recruitment agencies, and applying the Edenred Supplier Charter through procurement and RFP activity. Where higher‑risk relationships are identified, we prioritise engagement, transparency, and ongoing oversight to support alignment with our expectations and values.

Risk Management

We have assessed the risk of modern slavery within our own operations as low. The majority of our workforce consists of highly skilled professionals who are directly employed by Reward Gateway | Edenred and subject to robust and transparent recruitment processes. All employees are onboarded through structured internal procedures, and employee information is managed through a centralised HR system, supporting visibility, consistency, and compliance.

Where we partner with recruitment agencies, these organisations are selected based on their alignment with our ethical standards and undergo verification before engagement. While these agencies are not part of our direct operations, and therefore carry a degree of inherent risk outside our immediate control, we remain mindful of this exposure and seek to work with partners who share our values.

A small proportion of our workforce is engaged on temporary or fixed‑term contracts. These roles relate to professional services and are governed by contractual terms that comply with applicable local labour laws. We do not employ seasonal or casual workers, and we are proud to be an accredited UK Living Wage Employer. 

Risks We May Contribute to

The most significant potential risk identified relates to our extensive network of more than 2,500 retail partners. These partnerships are managed both directly, through in‑house retailer partnership teams, and indirectly, via affiliate networks.

Many of our retail partners are global organisations with complex, multi‑tiered supply chains that can extend into regions where the risk of human rights abuses is higher. In addition, some smaller retail partners may not be legally required to comply with modern slavery legislation, which can limit transparency and make risk assessment more challenging.

Risks We May Be Directly Linked to

We have identified a relatively low risk of modern slavery within the remainder of our supply chain. The primary area of potential risk is associated with technology and infrastructure providers, many of which operate globally and rely on raw materials sourced from regions with elevated modern slavery and human rights risks.

While these risks sit beyond our direct operations, we recognise our responsibility to understand, assess, and engage with suppliers and partners to promote responsible practices and continuous improvement. 

How We Put Our Stance into Practice

Speak Up
Reward Gateway | Edenred encourages employees, clients, suppliers, and other business partners to raise concerns about potential or actual modern slavery risks connected to our operations or supply chain. Our reporting channels are designed to be accessible, confidential, and free from fear of retaliation. Concerns can be raised with a line manager, the People Team, or via the Edenred SAFE Channel, a confidential and accessible whistleblowing system that allows employees and third parties to raise concerns safely and without fear of retaliation.

Employee Handbooks
Reward Gateway | Edenred maintains four location‑specific Employee Handbooks, reflecting the countries in which we operate. Each handbook sets clear expectations around behaviour and conduct when representing the business, in line with local legislation and requirements. Together, they reinforce our commitment to ethical business practices—both within our own operations and when working with third parties—and support a culture of accountability, respect, and integrity across the organisation.

Training and Awareness
We provide employees with education on modern slavery risks, indicators, and reporting mechanisms, and use internal communications and our engagement platform to reinforce awareness and understanding. This ensures our teams are informed, vigilant, and confident in recognising and raising concerns where they arise.

Procurement and Partner Engagement
Our procurement approach is aligned with Edenred’s Sustainable Procurement Policy and is underpinned by the Edenred Supplier Charter. We work with reputable partners and seek confirmation that suppliers understand and adhere to the ethical, human rights, and labour standards expected when working with Reward Gateway | Edenred.  

Agency Workers
When engaging agency workers, we work only with reputable employment agencies. New agencies are subject to verification processes to ensure their recruitment and employment practices align with our ethical standards before workers are engaged.

Edenred IDEAL CSR Strategy
As part of the Edenred Group, we align to the IDEAL CSR strategy, which reflects Edenred’s purpose to make the world of work a better place for all. IDEAL is built on three pillars:

• People – improving quality of life and being an employer of choice

• Planet – protecting the environment and committing to a Net Zero Carbon pathway by 2050

• Progress – creating value responsibly

This strategy underpins our approach to human rights, ethical conduct, and responsible business practices. 

CSR / ESG Correspondents
Our CSR and ESG Correspondents are colleagues from across the business responsible for developing, delivering, and monitoring our Social Value Strategy. They oversee CSR reporting, support compliance with modern slavery legislation across our operating countries, and regularly report progress to Edenred Group headquarters in Paris.

Events, Networks and Advocacy
Through our extensive network of employers and HR leaders, and via our events and content, we help raise awareness of modern slavery and promote responsible employment practices, using our platform to highlight the importance of ethical supply chains.

Our Products and Technology
Reward Gateway’s engagement platform enables organisations to communicate transparently with their employees. We use our own platform to raise internal awareness of modern slavery risks and prevention, and we also support small modern slavery charities by providing access to our products free of charge.

Actions Taken in the Last 12 Months

Over the past 12 months, Reward Gateway | Edenred has continued to strengthen its approach to preventing modern slavery and promoting ethical and responsible business practices. Key actions include:

• Strengthening speak‑up mechanisms

  We reviewed and enhanced our whistleblowing policy and processes and introduced the Edenred SAFE Channel, a confidential and accessible whistleblowing system that allows employees and third parties to raise concerns safely and without fear of retaliation.

• Review and update of UK employment contracts

  In late 2024 and early 2025, we undertook a comprehensive review and update of our UK employment contracts to ensure continued compliance with the latest legislative and regulatory requirements. As part of this review, we strengthened and expanded our Disciplinary and Grievance provisions to provide greater clarity, transparency, and consistency for employees. This work supports fair treatment, reinforces employee rights, and helps ensure that concerns can be raised and addressed clearly, respectfully, and in line with best practice.

• Aligning with Edenred’s Global IDEAL CSR strategy

  We fully adopted the Global Edenred IDEAL CSR Strategy, embedding its People, Planet, and Progress pillars across our business to align and amplify our social responsibility, human rights, and sustainability efforts with Edenred Group practices.

• Enhancing supplier due diligence

  We embedded the Edenred Supplier Charter into our Request for Proposal (RFP) processes, ensuring that ethical standards, human rights expectations, and modern slavery considerations are clearly communicated and applied when engaging new suppliers.

Assessing the Effectiveness of These Actions

We recognise that the risk of modern slavery is not static, and we remain committed to continuously improving our approach to identifying, preventing, and addressing these risks. We assess the effectiveness of our actions through the following measures:

• Annual review of our Modern Slavery Statement, ensuring it remains relevant, accurate, and reflective of our operations, supply chain, and evolving risks.

• Monitoring and reporting of concerns and incidents, including any alleged breaches of modern slavery practices raised through our whistleblowing and speak‑up channels, such as the Edenred SAFE Channel.

• Ongoing awareness and capability‑building, including identifying opportunities to increase understanding of modern slavery risks among our leaders and employees through training, conversations, and internal communications.

• Oversight of supplier engagement, including the rollout and uptake of the Edenred Supplier Charter within procurement and RFP processes, and review of higher‑risk supplier relationships where applicable.

Together, these measures help us understand whether our approach is working as intended and where further action or improvement may be required. 

Looking Ahead

Over the next 12 months, we will continue to build on our approach to identifying, preventing, and addressing the risk of modern slavery and human trafficking within our business and supply chain. Our focus will remain on collaboration, transparency, and continuous improvement. Our key ambitions include:

• Extending adoption of the Edenred Supplier Charter

  We will work to progressively introduce and embed the Edenred Supplier Charter with our existing suppliers, prioritising those identified as higher risk, and supporting understanding and alignment through engagement rather than disengagement.

• Strengthening supplier engagement and oversight

  We will continue to refine how we assess and monitor modern slavery risks within our supply chain, including reviewing existing supplier information, improving visibility where possible, and engaging partners in open dialogue about ethical practices and expectations.

• Enhancing internal awareness and capability
  We will continue to raise awareness among employees about modern slavery risks, indicators, and reporting channels, ensuring colleagues feel informed, confident, and supported to speak up if concerns arise.

• Embedding modern slavery considerations into business processes

  We will further integrate modern slavery risk considerations into relevant internal processes, including procurement, partner selection, and governance frameworks, to support consistent and responsible decision‑making.

• Strengthening reporting and review

  We will continue to review the effectiveness of our policies, controls, and reporting mechanisms, using insights from whistleblowing, supplier engagement, and internal feedback to inform future improvements.

Through these actions, we aim to deepen our understanding of risk, strengthen our partnerships, and continue using our influence responsibly to support fair treatment and respect for human rights across our operations and value chain.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 (Cth),  and constitutes Reward Gateway | Edenred’s slavery and human trafficking statement for the financial year ending 2025. It was approved by the Board of Directors.

Signed: 
Thierry Aflalo
Managing Director (Reward Gateway | Edenred)
April 2026

Past versions of Modern Slavery and Human Trafficking Statements:

• The 2024 Slavery and Human Trafficking Statement from Reward Gateway

• The 2022-2023 Slavery and Human Trafficking Statement from Reward Gateway

• The 2021 Slavery and Human Trafficking Statement from Reward Gateway

• The 2020 Slavery and Human Trafficking Statement from Reward Gateway

• The 2019 Slavery and Human Trafficking Statement from Reward Gateway

• The 2018 Slavery and Human Trafficking Statement from Reward Gateway

• The 2017 Slavery and Human Trafficking Statement from Reward Gateway